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TED CRUZ COMMITIEES: TEXAS ARMED SERVICES COMMERCE JUDICIARY ~nitrd ~tatrs ~rnatr RULES AND ADMINISTRATION JOINT ECONOMIC COMMITTEE September 1 L 2018 718 The Honorable Ajit Pai Chairman Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554

Dear Chairman Pai,

It has come to my attention that the Federal Communication Commission is currently reviewing an application (File Number: 325-NEW-20180614-00001 ), received June 20, involving H&H Group USA LLC and XEWW. a Mexican broadcasting station. The application requests a permit for to deliver programs to foreign broadcast stations pursuant to 47 U.S.C 325(c). Approving the application would permit H&H Group USA LLC to use XEWW to broadcast: ·'a full range of Mandarin Chinese language programming on station XEWW-AM including music, entertainment, weather report. local (LA) traffic report and local Chinese community news."

The Commission has previously explained that Section 325(c) is ''intended primarily to address two problems: objectionable programming and harmful interference by foreign stations." I am concerned that approving this application would enhance the ability of the (CPC) to broadcast objectionable political propaganda into America and to interfere in domestic American politics. I respectfully request that the Commission deny the H&H Group's pending application.

The application states that the applicants are entirely domestic American persons and entities: .. Applicant. .. will be 100% owned by H&H Group USA LLC, a New York limited liability company. Vivan Huo, a U.S. citizen owns 97% of the membership interests in H&H Group USA LLc:·. There are many troubling facts that are not included in the application, which deserve further review.

According to its corporate website, "H&H Capital assists PRC companies with finding strategic investors from around the globe" and "work[s] with Chinese companies interested in buying U.S. companies or the Chinese rights to U.S. brands." It was founded by Ms. Huo, who is described on the website as "native of '· who ·'has conducted in-depth research and analysis of major financial, legal, and business news including ... key legal issues facing Chinese state­ owned enterprises, among other topics."

H&H Capital's corporate website also states that Ms. Huo ''spent half a decade as the New York correspondent for one of 's largest publications." recently reported that Ms. Huo worked in New York as a correspondent for Global Times, which is owned by the People's Daily, an official newspaper of the CCP, registered under the Foreign Agents Registration Act.

SUITE 961 SUITE 410 SUITE 1420 SUITE 1603 SUITE 950 SUITE 501 SUITE SR-404 300 E. 8 TH STREET, 3626 NORTH HALL STREET, 808 TRAVIS STREET, 200 SOUTH 10TH STREET, 9901 IH- 10 WeST, 305 SOUTH BROADWAY, RUSSELL BUILDING AUSTIN, TX 78701 DALLAS, TX 75219 HOUSTON, TX 77002 M CALLEN, TX 78501 SAN A NTONIO, TX 78230 TYLER, TX 75702 WASHINGTON, DC 20510 (512) 916-5834 (214} 599-8749 (713} 718-3057 (956} 886-7339 (210} 340- 2885 (903} 593-5130 (202} 224-5922 The actual beneficiary owner of this deal is reportedly Phoenix TV. Though "Phoenix Satellite TV" does not appear anywhere in the H&H Group's application, the address listed for programing content - 3 810 Durbin St., Irwindale, CA 91706 - is a building owned by Phoenix Satellite TV USA. According to the Washington Free Beacon, the H&H Group recently hired Jackie Pang, who has been a Phoenix television reporter for decades. According to the Epoch Times "a recruiting advertisement placed by Phoenix TV's U.S. branch on WeChat, the popular social media platform, seeks ·program producers, narrators, hosts, and ad sales managers' for 'AM 690, Phoenix U Radio.,,.

Phoenix Satellite Television US is a subsidiary of Beijing Phoenix TV, based in . The People's Republic of China (PRC) exerts control over Chinese media and the control extends to Phoenix: in 2009 testimony to the U.S. Economic and Security Review Commission on China, Anne Marie-Brady, a Global Fellow at the Wilson Center, said, "Phoenix is nominally privately­ owned; however its current main investor is the State-owned enterprise ." In 2016, for example, Phoenix broadcast the forced confessions of five Hong Kong booksellers for violating PRC censorship law.

CCP state-run China Radio International (CRI) president Wang Gengnian has described China·s use of local media in foreign countries as "borrowing a boat to go out to sea." Wang emphasized the need for China to target foreign media to "compete to lead international public opinion" and "set the agenda" on the global stage. As part of the "borrowed boat" strategy CRI has previously partnered with foreign radio stations such as Turkish FM station Yon Radyo which was utilized to present the CCP narrative in the aftermath of the 2009 Orfunqi riots. According to Wang, positive feedback from Turkish listeners demonstrated the benefits of "effective international broadcasting targeted at a specific group."

The Chinese Communist Party is waging an information warfare campaign to undermine American democracy. The decision before the Commission risks allowing the CPC to broadcast government-approved propaganda into Southern , one of the most densely populated regions in America of Mandarin speakers, to boost that warfare campaign. The Commission should reject the application, given the unresolved and undisclosed details surrounding the application.

Sincerely, /-/6 United States Senator

cc: GLR Southern California LLC H&H Group USA LLC Chinese Sound of Oriental and West Heritage